mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010477.json

{
  "document_metadata": {
    "page_number": "31",
    "document_number": "663",
    "date": "06/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 31 of 77\nguards commented that they had never seen a non-violent, non-suicidal detainee subjected to such drastic conditions.21 The treatment was not based on any claim or evidence that Ms. Maxwell was suicidal, dangerous, violent, or in need of discipline. Quite the contrary. The policies and actions implemented to detain Ms. Maxwell violated clearly established rights of inmates to be free from punishment and unreasonable searches. Courts have been confronted with cases challenging conditions of confinement in the MDC. See Turkman v. Hasty, 789 F.3d 218 (2d Cir. 2015), which involved many of the same challenges to conditions of confinement.\n\nThere can be no dispute that Ms. Maxwell's detention was far more arduous and constituted a more serious penalty than conventional detention is general population. While the hardship of imprisonment is normally measured in quantitative terms, i.e., by the length of the prison term, the hardship and deprivations experienced by Ms. Maxwell also had a qualitative aspect. The difference between Ms. Maxwell's isolation and typical prison conditions is so pronounced that they differ not only in degree but in nature. This distinction demands a different calibration whereby each day spent in isolation - especially where isolation is not based on any behavior manifested by the inmate and while the inmate is presumed innocent - should result in an enhanced time-served credit.\n\nIncarceration During the Pandemic Supports a Well-Recognized Sentence Reduction\n\nCourts in this district and elsewhere have acknowledged COVID hardship as a basis for downward variances from the guidelines. But even \"before the current pandemic, courts had recognized that periods of pre-sentence custody spent in unusually hard conditions merited recognition by courts in measuring the just sentence.\" United States v. Romero, 15 CR. 445-18\n\n21 Other similarly charged defendants, e.g., Keith Raniere , 18 Cr. 204 (NGG) (NEXIUM case), and Robert Sylvester Kelly, aka \"R. Kelly,\" 19 Cr. 286 (AMD), were detained in general population.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 31 of 77",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "guards commented that they had never seen a non-violent, non-suicidal detainee subjected to such drastic conditions.21 The treatment was not based on any claim or evidence that Ms. Maxwell was suicidal, dangerous, violent, or in need of discipline. Quite the contrary. The policies and actions implemented to detain Ms. Maxwell violated clearly established rights of inmates to be free from punishment and unreasonable searches. Courts have been confronted with cases challenging conditions of confinement in the MDC. See Turkman v. Hasty, 789 F.3d 218 (2d Cir. 2015), which involved many of the same challenges to conditions of confinement.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "There can be no dispute that Ms. Maxwell's detention was far more arduous and constituted a more serious penalty than conventional detention is general population. While the hardship of imprisonment is normally measured in quantitative terms, i.e., by the length of the prison term, the hardship and deprivations experienced by Ms. Maxwell also had a qualitative aspect. The difference between Ms. Maxwell's isolation and typical prison conditions is so pronounced that they differ not only in degree but in nature. This distinction demands a different calibration whereby each day spent in isolation - especially where isolation is not based on any behavior manifested by the inmate and while the inmate is presumed innocent - should result in an enhanced time-served credit.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Incarceration During the Pandemic Supports a Well-Recognized Sentence Reduction",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Courts in this district and elsewhere have acknowledged COVID hardship as a basis for downward variances from the guidelines. But even \"before the current pandemic, courts had recognized that periods of pre-sentence custody spent in unusually hard conditions merited recognition by courts in measuring the just sentence.\" United States v. Romero, 15 CR. 445-18",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "21 Other similarly charged defendants, e.g., Keith Raniere , 18 Cr. 204 (NGG) (NEXIUM case), and Robert Sylvester Kelly, aka \"R. Kelly,\" 19 Cr. 286 (AMD), were detained in general population.",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Keith Raniere",
      "Robert Sylvester Kelly"
    ],
    "organizations": [
      "MDC"
    ],
    "locations": [],
    "dates": [
      "06/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 663",
      "789 F.3d 218",
      "18 Cr. 204",
      "19 Cr. 286",
      "15 CR. 445-18"
    ]
  },
  "additional_notes": "The document appears to be a court filing discussing the detention conditions of Ms. Maxwell and their impact on her sentence. The text is printed and there are no visible stamps or handwritten notes."
}